Roberta Lilly v. Frank Bisignano, Commissioner of Social Security

1 FORSLUND LAW, LLC Jacqueline A. Forslund # 154575 P.O. Box 4476 Sunriver, OR 97707 Telephone: 541-419-0074 Fax: 541-593-4452 Email: [email protected] Attorney for Plaintiff 7 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA ROBERTA LILLY, ) Case No. 2:24-CV-01504-AC ) 10 Plaintiff ) STIPULATION AND PROPOSED ) ORDER FOR AWARD OF ATTORNEY’S v. ) FEES UNDER THE EQUAL ACCESS TO ) JUSTICE ACT (EAJA) FRANK BISIGNANO, ) Commissioner of Social Security, ) ) 14 Defendant ) ) ____________________________________) IT IS HEREBY STIPULATED by and between the parties through their undersigned counsel, subject to the approval of the Court, that Plaintiff be awarded attorney fees and expenses in the amount of TEN THOUSAND FIVE HUNDRED dollars and ZERO cents ($10,500.00) under the Equal Access to Justice Act (EAJA), 28 U.S.C. § 2412(d).

20 After the Court issues an order for payment of EAJA fees and expenses to Plaintiff, the government will consider the matter of Plaintiff’s assignment of EAJA fees and expenses to Plaintiff’s attorney. The government’s ability to honor the assignment will depend on whether the fees and expenses are subject to an offset allowed under the United States Department of the Treasury’s Offset Program pursuant to Astrue v. Ratliff, 130 S.Ct. 2521 (2010). After the order of EAJA fees and expenses is entered, the government will determine if they are subject to an offset.

If it is determined that Plaintiff’s EAJA fees and expenses are not subject to an offset under Astrue v. Ratliff, 130 S.Ct. 2521 (2010) and the Department of Treasury’s Offset Program, then the check for EAJA fees and expenses shall be made payable to Jacqueline A. Forslund, based upon Plaintiff’s assignment of these amounts to Plaintiff’s attorney.

1 The parties agree that whether these checks are made payable to Plaintiff or Jacqueline A. > || Forslund, such checks shall be mailed to Plaintiffs attorney.

3 This stipulation constitutes a compromise settlement of Plaintiff's request for EAJA attorney fees, and does not constitute an admission of liability on the part of Defendant under the EAJA or otherwise. Payment of the agreed amount shall constitute a complete release from, and bar to, any and all claims that Plaintiff and/or Plaintiff's Counsel may have relating to EAJA attorney fees in connection with this action.

8 Respectfully submitted, || Date: December 23, 2025 JACQUELINE A. FORSLUND 10 Attorney at Law 1 /s/Jacqueline A. Forslund JACQUELINE A. FORSLUND 13 Attorney for Plaintiff 14 Date: December 23, 2025 KIMBERLY A. SANCHEZ 1 Acting United States Attorney MATHEW W. PILE 16 Head of Program Litigation 1 Social Security Administration | Law & Policy is /s/Oscar Gonzalez De Llano 19 OSCAR GONZALEZ DE LLANO Special Assistant United States Attorney 20 *By email authorization Attorney for Defendant 23 ORDER || APPROVED AND SO ORDERED 25 ~ 26 Dated: December 29, 2025 Attt0r— Lane ALLISON CLAIRE 27 UNITED STATES MAGISTRATE JUDGE Lilly v. Bisignano Stipulation and Proposed Order E.D. Cal. 2:24-cv-01504-AC